6/28/2019 8:56:31 AM French Digital Services Tax: final adjustments prior to enactment of the Bill? By Franck Morhain On 26 June 2019, the Commission Mixte Paritaire, a parliamentary committee composed of an equal number of representatives from the French...
6/28/2019 12:00:00 AM Irish Tax Appeals Commission Decision Relating To a Delaware LLC and Irish Group Loss Relief By Paul Fahy In a recent decision, concerning claims for group loss relief by Irish subsidiary companies of a Delaware LLC, the Irish Tax Appeals...
6/17/2019 12:00:00 AM Co-opting digital companies into tax law enforcement By Tanja Velling Today, The Times reported that some 38,000 online sellers registered for VAT in the UK in 2017-18, compared to 29,000 in the previous...
6/12/2019 12:00:00 AM Taxing the digital economy: impact assessments will help identify winners and losers By Zoe Andrews The G20 has endorsed the OECD's work programme consisting of the two-pillar approach which was the subject of Tanja Velling's recent...
6/11/2019 9:17:00 AM How low is low taxation? – The reform of the German CFC rules By Markus Ernst Germany's controlled foreign corporation rules (CFC rules, Hinzurechnungsbesteuerung) date back to 1974 and have never really been...
6/8/2019 12:00:00 AM The tax residence of companies. A matter of fact, or a fact that does not matter? By Andrea Manzitti In her recent post, Tanja Velling highlights some of the uncertainties in the UK around the tax residence of a company. This is not just...
6/7/2019 7:46:11 AM New Residents First! By Andrea Manzitti Italy is facing a dramatic outflow of “human capital”. According to Eurostat, only Romania and Poland pips Italy to the post in terms of...
6/7/2019 7:43:04 AM All clear on tax residence? By Tanja Velling The First-tier Tax Tribunal's unhelpful decision in the Development Securities case has been reversed by an Upper Tribunal decision which...
6/6/2019 11:02:57 AM Decision time for the UK Government on the CFC State aid challenge By Slaughter and May The time limit for the UK to appeal the EU’s State aid decision in relation to the UK’s CFC regime is fast approaching, and we still do...
6/6/2019 9:45:23 AM Dutch interest free loan structures at risk after Huhtamäki? By Maarten van der Weijden The EC has decided to open an in-depth investigation into whether Luxembourg may have granted illegal state aid to the Huhatmäki group....